Welcome to The 1st Stop Group Limited’s privacy notice. The 1st Stop Group Limited company registration 05438114, with its registered office address situated at 10 Whitehills Business Park, Whitehills, Blackpool, FY4 5LW.
The 1st Stop Group consists of 1st Stop Home Loans Limited, company registration number 05667257, with its registered office address situated at 10 Whitehills Business Park, Whitehills, Blackpool, FY4 5LW; 1st Stop Car Finance Limited company registration number 07213812, with its registered office address situated at 10 Whitehills Business Park, Whitehills, Blackpool, FY4 5LW and 1st Stop Personal Loans Limited company registration number 08457740, with its registered office address situated at 10 Whitehills Business Park, Whitehills, Blackpool, FY4 5LW, (“1st Stop Group”).
The 1st Stop Group companies are registered with the ICO as Data Controllers with the following details:
The 1st Stop Group Limited – ICO Registration Number – ZA011770
1st Stop Home Loans Limited – ICO Registration Number – Z1245955
1st Stop Car Finance Limited – ICO Registration Number – Z3274560
1st Personal Loans Limited – ICO Registration Number – ZA006742
The 1st Stop Group respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you apply for a loan with us and tell you about your privacy rights and how the law protects you.
Please also use the Schedule to understand the meaning of some of the terms used in this privacy notice.
Purpose of this privacy notice
This privacy notice aims to give you information on how the 1st Stop Group collects and processes your personal data, including any data you may provide via a broker or via our website www.1ststop.co.uk (“the Website”) when you make an application for one of our loan products.
The Website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
1st Stop Home Loans Limited, 1st Stop Car Finance Limited and 1st Stop Personal Loans Limited are the Data Processor up to the point whereby they provide you with a loan, upon which they become the Data Controller and become responsible for your personal data (collectively referred to as “1st Stop Group”, “we”, “us” or “our” in this privacy notice).
The 1st Stop Group is made up of different legal entities, 1st Stop Home Loans Limited, 1st Stop Car Finance Limited and 1st Stop Personal Loans Limited. This privacy notice is issued on behalf of the 1st Stop Group so when we mention 1st Stop Group, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the 1st Stop Group responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us. The 1st Stop Group Limited is the controller and responsible for the Website.
We have appointed a Data Protection Officer (“DPO”) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Data Protection Officer: Mr Michael Billington
Email address: firstname.lastname@example.org
Postal address: 10 Whitehillls Business Park, Whitehills, Blackpool, FY4 5LW
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 6th July 2018 and historic versions can be obtained by contacting us at email@example.com
The data protection law in the UK changed on 25 May 2018. This privacy notice sets out your rights under the new laws.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes address, email address and telephone numbers.
- Financial Data includes bank account details, salary details, assets, liabilities, details on any dependants, income and expenditure and payment card details.
- Transaction Data includes details about payments to and from you, details of any arrears, details of arrears charges and associated costs.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Website.
- Profile Data includes your username and password, loan applications made, payments made by you, your financial situation, marketing preferences, feedback and survey responses.
- Usage Data includes information about how you use our Website, loan products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third party supplier and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
We may however, sometimes collect sensitive personal data but we will not hold this information without your express permission.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to provide the loan product we are trying to enter into with you. In this case, we may have to decline the loan application but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by completing an application form via our Website or via a broker or introducer or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you;
- apply for our loan products;
- create an account on our Website;
- subscribe to our on-line portal;
- request marketing to be sent to you;
- complete a survey; or
- give us some feedback.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
- analytics providers such as Google based outside the EU;
- advertising networks such as Google and Facebook based outside the EU; and
- search information providers such as Google based outside the EU.
- Contact, Financial and Transaction Data from providers of technical, payment services based inside the EU.
- Identity and Contact Data from the Credit Reference agencies we use based inside the EU.
- Identity and Contact Data from publicly available sources such as the Electoral Register based inside the EU.
- Cifas, the Fraud Prevention Agency based inside the EU.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to assess your suitability for one of our loan products;
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you where we do not believe we have a Legitimate Interest to send you such marketing.
You will be asked about your marketing preferences at the point you interact with us and you have the right to withdraw consent to marketing at any time by contacting us at firstname.lastname@example.org.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To consider your application for a loan||(a) Identity
(f) Marketing and Communications
|Consideration of where or not you meet our criteria/suitability for one of our loan products.|
|To register you as a new customer.||(a) Identity
(e) Marketing and Communications
|Performance of a contract with you|
|To process and fund your loan including:
(a) Manage payments, fees and charges.
(b) Collect and recover money owed to us.
(f) Marketing and Communications
|(a) Performance of a contract with you
|To manage our relationship with you which will include:
(a) Meeting our regulatory obligations including providing you with information relation to your loan.
(b) Managing your loan account.
(d) Asking you to leave a review or take a survey.
(f) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
(d) Necessary for our legitimate interests (to recover debts due to us)
|To enable you to complete a survey.||(a) Identity
(e) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business).
(c) To understand the customer experience and provide better customer services for our customers.
|To administer and protect our business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation.
|To deliver relevant Website content to you and measure or understand the effectiveness of the content we serve to you||(a) Identity
(f) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to provide a better customer experience, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences.||(a) Technical
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep the Website updated and relevant, provide a better customer experience, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity
(f) Marketing and communication
|Necessary for our legitimate interests (to develop our products/services and grow our business).
Develop better loan products for our customers.
|To collect any debt that may occur in relation to your loan product.||(a) Identity
|Necessary for our legitimate interests to collect any outstanding arrears in relation to your loan product.
We may also use third parties such as credit
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can unsubscribe or amend your marketing preferences at any time by contacting us at email@example.com
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
Using your personal data for marketing
We may send customers marketing about similar products and services by post, telephone, email, SMS and through digital channels. Digital channels includes social media and similar such digital marketing channels.
You can object to receiving marketing from us at any time. Please email firstname.lastname@example.org to unsubscribe.
You will receive marketing communications from us if you have requested information from us or been provided with a loan product by us, or if you provided us with your details when you applied for a loan product from us and, in each case, you have not opted out of receiving that marketing.
We consider that it is within our legitimate interests to send you information about our products and services for marketing purposes.
In the event we wish to conduct some promotion with selected third parties we will obtain your express opt-in marketing consent, and inform you of which company we wish to share your details with, before we share your personal data with any company outside the 1st Stop Group of companies for marketing purposes.
You can ask us or any third parties we may to stop sending you marketing messages at any time by emailing us at email@example.com and confirming what you want us to do.
Where you opt out of receiving these marketing messages, this will only apply to marketing preferences and not how we communicate to you in respect of any current loan product you may have with us.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at firstname.lastname@example.org
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- Internal Third Parties as set out in the Schedule.
- External Third Parties as set out in the Schedule.
- Specific third parties listed in the table in the Schedule.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We do not transfer your personal data outside the European Economic Area (EEA).
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for legal and regulatory purposes.
In certain circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. For further details please refer to the Schedule below.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
- LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and loan products and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at email@example.com
Performance of Contract means processing your personal data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
- THIRD PARTIES
Internal Third Parties
Other companies in the 1st Stop Group acting as joint controllers or processors and who are based within the United Kingdom, and provide IT and system administration services and undertake leadership reporting].
External Third Parties
- Service providers acting as processors based in the UK who provide data hosting, data storage, electronic messaging services, call recording services and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, debt recovery agents, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, debt recovery services, tracing agents, repossession agents, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
- Cifas, a fraud prevention agency based in the United Kingdom who provide fraud prevention services and who we also report to.
- Customer satisfaction survey administrators.
- Credit Reference Agencies, in order to process your application, we will perform credit and identity checks on you with one or more credit reference agencies (“CRAs”). Where you take banking services from us we may also make periodic searches at CRAs to manage your account with us.
To do this, we will supply your personal information to CRAs and they will give us information about you. This will include information from your credit application and about your financial situation and financial history. CRAs will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information.
We will use this information to:
- Assess your creditworthiness and whether you can afford to take the product;
- Verify the accuracy of the data you have provided to us;
- Prevent criminal activity, fraud and money laundering;
- Manage your account(s);
- Trace and recover debts; and
- Ensure any offers provided to you are appropriate to your circumstances.
We will continue to exchange information about you with CRAs while you have a relationship with us. We will also inform the CRAs about your settled accounts. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs.
When CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other lenders.
If you are making a joint application, or tell us that you have a spouse or financial associate, we will link your records together, so you should make sure you discuss this with them, and share with them this information, before lodging the application. CRAs will also link your records together and these links will remain on your and their files until such time as you or your partner successfully files for a disassociation with the CRAs to break that link.
The identities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained in more detail at www.callcredit.co.uk/crain. The Credit Reference Agency Information Notice is also accessible from each of the three CRAs – clicking on any of these three links will also take you to the same document:
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.